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Nursing Facility Bulletin 201: Updates to Instructions for Nursing Facility Fee-for-Service Payments: MDS 3.0 Assessments
MassHealth·MA · Geriatrics·Specialty Services
Effective date
Jul 1, 2026
We identified it
Jul 31, 2026
Summary
MassHealth updated nursing facility MDS 3.0 assessment payment instructions effective July 1, 2026, superseding Bulletin 197. Key changes include: (1) new guidance on retroactive eligibility and modified MDS assessments, (2) expanded MDS audit requirements to include up to 100% of admission, quarterly, and annual assessments with focus on modified assessments resulting in higher PDPM scores for claims dated 10/1/2023 or later, and (3) clarified auditing procedures for behavioral indicator add-on claims. Nursing facilities must ensure MassHealth provider ID and member ID are on all MDS submissions or resubmit modified assessments.
Action Required
REQUIREMENTS:
— By July 1, 2026 (immediate): Billing and compliance teams must review and implement changes from Bulletin 201, which supersedes Bulletin 197 (January 2026).
— Immediately: Verify that all MDS assessment submissions include BOTH the MassHealth provider ID and MassHealth member ID. If either is missing, nursing facility administrative staff must submit a corrected/modified MDS assessment per CMS RAI Manual Chapter 5.7. Claims cannot be paid without both identifiers.
— By July 1, 2026 and ongoing: Billing team must prepare for expanded MDS audits. MassHealth will now audit up to 100% of admission, quarterly, and annual assessments submitted for any paid claims with service dates on or after October 1, 2023. Prioritize documentation for modified assessments that resulted in higher PDPM scores than original assessments.
— Weekly (every Wednesday): Administrative/compliance staff must review two reports available in MMIS:
- ELG-402 (MDS Submission Success Report): Confirm MassHealth received appropriate MDS assessments for facility members
- ELG-404 (MDS Submission Error Report): Identify rejected assessments and submit corrections immediately
— By July 1, 2026: Billing team must understand new sections on retroactive eligibility and modified MDS assessments (page 5) and clinical review procedures for behavioral indicator add-on audits (page 7).
— Ongoing compliance: Ensure all MDS assessments comply with 92-day submission windows (with 21-day grace period for MassHealth payment acceptance). Assessments outside this window will result in payment interruption or denial.
CONSEQUENCES: Missing MassHealth provider ID or member ID will require modified MDS resubmission and delay/deny payment. Non-compliant assessments submitted outside windows will result in unpaid claims. Expanded audits (effective retroactively to 10/1/2023) may result in recoupment of overpayments identified in modified assessments.